Madrid Vs Mapoy

MADRID vs MAPOY
Spouses Bonifacio and Felicidad Mapoy are the absolute owners of two parcels of land.
On April 4, 1988, respondent-plaintiffs sought to recover possession of the properties through accion
publiciana filed before RTC of Manila against Gregorio Miranda, Bernardo, and Madrid. They alleged
that they acquired the properties from spouses Castelo under a Deed of Absolute Sale. They merely
tolerated the petitioner-defendants continued occupancy and possession until such became illegal
when demands to vacate the property were made.
Despite the demands, petitioner-defendants continued to occupy and unlawfully withhold possession
of the properties from the respondent-plaintiffs, to their damage and prejudice. Efforts to amicably
settle the case proved futile, leaving respondent-plaintiffs to file for ejectment, which was dismissed.
Subsequently, they filed a complaint for accion publiciana, praying for recovery of possession of the
properties.
The Mirandas countered that Gregorio owned the properties by virtue of an oral sale made in his
favor by the original owner Vivencio Antonio. They claimed that in 1948, Gregorio Miranda was
Antonio’s carpenter, and they had a verbal contract for Miranda to stay in, develop, fix, and guard the
properties; in 1972, Antonio gave the properties to Gregorio Miranda in consideration of his more
than 20 years of loyal service. However, the RTC ultimately ruled in favor of respondent-plaintiffs.
Upon appeal, the CA affirmed the decision of RTC.
ISSUES:
1. Who has better right of possession/ownership
2. Whether fraud attended the acquisition of title by the respondents
3. Whether the petitioners’ continuous residence for more than 10 years entitle them to the rights
and privileges granted by Presidential Decree 1517 [occupancy of Miranda since 1948, Bernardo since
1966 and Madrid since 1973]
RULING:
1. The spouses Mapoy has better right of ownership.
As a matter of law, a Torrens Certificate of Title is evidence of indefeasible title of property in favor of
the person in whose name the title appears.
The title holder is entitled to all the attributes of ownership of the property, including possession,
subject only to limits imposed by law.
Madrid, Bernardo and Miranda based their claim of ownership on their oral sale and occupation. But
the spouses Mapoy has better right of ownership as they have a TCT under their name.
2. No. The very purpose of the Torrens system aside from perfecting the title and rendering it
indefeasible, is that it also protects the holder from collateral attack. As the court has stated, “to
permit a collateral attack on the respondents’ title is to water down the integrity and guaranteed legal
indefeasibility of a Torrens title.
In the case, the claim that fraud attended the acquisition is a collateral attack on the title. The Court
stated that such attack cannot be entertained to impugn the validity of the respondent’s title to their
property.
Compared to Suarez vs Emboy:

The case of Suarez vs Emboy has a justification of exclusion from the general rule of indefeasibility of
title, as there were circumstances that exist to abate the ejectment proceedings, where ownership
over the subject lots is presented as an issue.
3. No. They cannot be granted protection under PD 1517

Section 6 of PD 1517 states that “legitimate tenants of 10 years or more, who have built their homes
on the lands and who have continuously resided thereon for the past 10 years, shall not be
dispossessed of their occupied lands and shall be allowed the right of first refusal to purchase these
lands within a reasonable time and reasonable prices.
To qualify for protection under PD 1517, the claimant must be:

a. a legitimate tenant of the land for 10 years or more
b. Must have built his home on the land by contract
c. Has resided continuously in the land for the last 10 years
Also, PD1517 defined tenant as the rightful occupant of the land but does not include those whose
presence on the land is merely tolerated and without the benefit of contract, those who entered the
land by force or deceit, or those whose possession is under litigation.
Therefore, the petitioners whose occupation has been merely tolerated by the owners fall outside the
coverage of PD1517.

Madrid Vs Mapoy

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MADRID vs MAPOY

Compared to Suarez vs Emboy:

3. No. They cannot be granted protection under PD 1517

To qualify for protection under PD 1517, the claimant must be:

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